https://www.taxtmi.com/caselaws?id=792076 Cash shortage recorded in the assessee's proprietary concern could not be treated as deemed dividend under section 2(22)(e) because the Revenue failed to show that the discrepancy arose from the books of the company or that any payment or benefit was withdrawn from the company by a qualifying shareholder. The Tribunal noted that the cash balance comparison and the statement relied on by the Revenue related to the proprietary concern, not the company, so the factual basis for the deeming fiction was absent. On that material, the addition under section 2(22)(e) was held unsustainable and deleted. en-us Wed, 20 May 2026 00:00:00 +0530 Fri, 22 May 2026 07:06:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792076 Cash shortage recorded in the assessee's proprietary concern could not be treated as deemed dividend under section 2(22)(e) because the Revenue failed to show that the discrepancy arose from the books of the company or that any payment or benefit was withdrawn from the company by a qualifying shareholder. The Tribunal noted that the cash balance comparison and the statement relied on by the Revenue related to the proprietary concern, not the company, so the factual basis for the deeming fiction was absent. On that material, the addition under section 2(22)(e) was held unsustainable and deleted. Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792076